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Home My WebLink About09-2509 LAUREN BITTNER : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW KEITH NELSON : NO.09- d561 CIVIL TERM Defendant. : IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the Plaintiff, Lauren Bittner, by and through her attorney, Mark F. Bayley, and presents the within complaint for custody, representing as follows: 1. The Plaintiff, Laurent Bittner, is an adult individual residing at 39 Regency Woods North, Carlisle, PA 17015. 2. The Defendant, Keith Nelson, is an adult individual residing at 34 East Street, Mt. Holly, Pennsylvania 17065. 3. Plaintiff seeks custody of the following children: Name Present Residence Age D/OB Cadenze 39 Regency Woods North 3 8/31/05 Carlisle, PA 17015 Kailan 39 Regency Woods North 2 7/19/06 Carlisle, PA 17015 4. The children were born out of wedlock. 5. The relationship of the Plaintiff to the children is that of natural Mother. The Plaintiff currently resides with the above children, and: Name Relationship (to the children) Mayling Bittner Grandmother Elizabeth Bittner Aunt Lorraine Avery Aunt Adia Barber She is not married. Cousin 6. The relationship of the Defendant to the children is that of natural Father. The Defendant currently resides with his paramour, whose name is unknown. He is not married. 7. During the past five years, the children have resided with: Name Address Date Lauren Bittner 39 Regency Woods North Birth-present Carlisle, PA 17013 8. The Plaintiff has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the children is this or any other Court. 9. Plaintiff has no information of a custody proceeding concerning the children pending in any Court of this Commonwealth or any other state. 10. Plaintiff does not know of a person nor a party to the proceeding who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 11. The best interests and permanent welfare of the children require Plaintiff to have primary physical custody and for Defendant to have contact at times that serve the best interests of the children which may be agreed upon between the parties or otherwise be determined by the Court. WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody conciliation conference. Date: q- ( l? Respectfully submitted, BAYLEY & MANGAN ViWark F. Bayley, Esquire 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court ID # 87663 Attorney for Plaintiff LAUREN BITTNER Plaintiff, V. KEITH NELSON Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 09- IN CUSTODY CIVIL TERM VERIFICATION I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. a OF OF THE r Utz- °,!)a.1 ilZf 21,99 APR 21 Nl 1: 31 LAUREN BITTNER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH NELSON DEFENDANT 2009-2509 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, April 24, 2609 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, May 26, 2009 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl ac ueline M. Verne Es . Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ? ' ?,`Gr?`?r?ISI '.)F THE 2UQ4 APR 27 i' ll 10: 2.4 GU,??? } 27 / Oq - ec,? e,,? I ., L, L It> 194,? M . -?Wy IJF-y y -to 14. lkluoo-) 'uC4 spy ply ,a A?1? .f.t?...?y? PL MAY 2 7 2009,oj LAUREN BITTNER, Plaintiff V. KEITH NELSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-2509 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT ?j AND NOW, this y ' day of , 2009, upon consideration of the attached Custody Conciliati Report, it is ordered and directed as follows: 1. The Mother, Lauren Bittner and the Father, Keith Nelson, shall have shared legal custody of Cadenze Nelson, born August 31, 2005 and Kailan Nelson, born July 19, 2006. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the children including, but not limited to medical, dental, religious or school records, the residence address of the children and the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Both parents shall be entitled to full participation in all educational and medical/treatment planning meetings and evaluations with regard to the minor children. Each parent shall be entitled to full and complete information from any physician, dentist, teacher or authority and copies of any reports given to them as parents including, but not limited to: medical records, birth certificates, school or educational attendance records or report cards. Additionally, each parent shall be entitled to receive copies of any notices which come from school with regard to school pictures, extracurricular activities, children's parties, musical presentations, back-to-school nights, and the like. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial physical custody as follows: A. Two weekends per month from Friday to Sunday as agreed by the parties. B. Such other times as the parties agree. 4. Holidays shall be shared as agreed by the parties. A 5. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. B'i J. cc: ark F. Bayley, Esquire, Counsel for Mother eith Nelson, pro se 34 East Street Mt. Holly Springs, PA 17065 l:.D P t sf D-q f? ?:?n _r, ?_ ? ? ? ?9 +'.F .. ri ? ?. U ?? __ .,. "??l?ii.? i LAUREN BITTNER, Plaintiff V. KEITH NELSON, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-2509 CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Cadenze Nelson August 31, 2005 Mother Kailan Nelson July 19, 2006 Mother 2. A Conciliation Conference was held in this matter on May 26, 2009, with the following in attendance: The Mother, Lauren Bittner, with her counsel, Mark F. Bayley, Esquire, and the Father, Keith Nelson, pro se. 3. The parties agreed to an Order in the form as attached. V ( ?? s -AG nn Date cqu ne M. Verney, Esquire Custody Conciliator